Skip to content
BOL Conferences
Thread Options
#1652319 - 01/18/12 07:44 PM DEP Filings
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
I am new at filing this paperwork and there were no notes left benind from the person who did these exemptions before. Anyone have any tips on what to look for before I get started?

Thanks.

Return to Top
BSA/AML/CIP/OFAC Forum
#1652347 - 01/18/12 08:12 PM Re: DEP Filings mdog76
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,352
Galveston, TX
Review the examination manual.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1653774 - 01/20/12 07:05 PM Re: DEP Filings mdog76
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The DOEP form is hopelessly out of date as revisions taking effect in January 2009 were never reflected on the form or its instructions other than the notation in Part V.

At one time FinCEN published the following as an amendment to the instructions:

To assist depository institutions in completing the DOEP, FinCEN Form 110, FinCEN is providing the following guidance for items affected by this final rule.
 Depository institutions should disregard any references to biennial renewals that appear on the face of FinCEN Form 110 (specifically, Part I, Item 1b, ‘‘Biennial renewal’’; Part II, Item 11; Part III, Item 19, second sentence; and Part V), as well as in the instructions to the form (specifically in the second paragraph under the heading ‘‘When and where to file’’; the second sentence under the heading ‘‘Specific Instructions’’ that begins, ‘‘Additionally, with regard to non-listed businesses. * * *’’); and the instruction to Item 11 under the heading ‘‘Exempt Person Information.’’
 Depository institutions should disregard Part II, Item 10a, ‘‘Bank’’ and ‘‘Government agency/Government authority.’’
Specific questions may be directed to the FinCEN Helpdesk by calling 800-949-2732, and selecting option 3.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z